The Supreme Court affirmed the dismissal of a court interpreter for falsifying Daily Time Records (DTRs) while attending law school. The Court held that dishonesty and falsification of official documents are grave offenses warranting dismissal, emphasizing the importance of integrity in public service. This ruling reinforces the principle that government employees must accurately reflect their work hours and duties, ensuring public trust and accountability.

The Case of the Commuting Court Interpreter: Can Honesty and Public Service Coexist?

This case originated from an anonymous complaint alleging that Liza Marie F. Abdullahi, a Court Interpreter, had been submitting falsified DTRs. The complaint stated that Abdullahi claimed to be working full-time at the Regional Trial Court (RTC) in Alfonso-Lista, Ifugao, while simultaneously attending law school at St. Louis University in Baguio City, more than 200 kilometers away. The anonymous complainant alleged that this arrangement had been tolerated by Abdullahi’s superiors.

An investigation by the Office of the Court Administrator (OCA) confirmed that Abdullahi was indeed enrolled in law school during the period in question. When confronted, Abdullahi admitted her enrollment but argued that she had authorization from her superior, Judge Demetrio D. Calimag, Jr., to conduct research in Baguio City due to the limited availability of legal resources in Alfonso-Lista. She also claimed that the Court Administrator had approved a detail at RTC-Br. 59 in Baguio City.

The Supreme Court found Abdullahi’s justifications unpersuasive. While acknowledging that Judge Calimag, Jr., had issued memoranda allowing Abdullahi to work from Baguio City, the Court determined that these directives were improper and did not excuse the falsification of her DTRs. The Court emphasized that Abdullahi’s primary duty as a Court Interpreter was to be physically present at her official station and perform her assigned tasks.

The Court noted that, even if Abdullahi had been authorized to conduct research, the distance between Alfonso-Lista and Baguio City made it impossible for her to fulfill her official duties while attending law school. Her DTRs reflected full-time work hours that were incompatible with her class schedule. As the Court found the Court interpreter had deliberately misrepresented her whereabouts, it deemed the offense nothing short of **Dishonesty** under Rule XIV, Sec. 23, of the *Omnibus Rules of the Civil Service* which dictates dismissal for the first offense. Thus, dishonesty was tantamount to falsification of an official document as enumerated under Civil Service Commission Memorandum Circular No. 30, Series of 1989, in its re *Guidelines in the Application of Penalties in Administrative Cases*.

“When a court employee is detailed at a specific station, she is expected to be physically present there, as recorded in the DTRs. Although a presiding judge may have the discretion to authorize an employee’s occasional absences therefrom on *official business*, such discretion certainly does not include authorizing the continued and prolonged absence of an employee on the pretext of conducting “research” in Baguio City when there was not even an iota of proof to show that respondent indeed conducted “research” as directed. Moreover, the designation of her position is “Court Interpreter” whose job description did not include “doing research work.””

Building on this principle, the Court emphasized the importance of upholding ethical standards in the judiciary. The judiciary is composed of court employees and court officers, thus all should exhibit excellent standards and irreproachable behavior at all times so as to preserve the Court’s image. By engaging in dishonest behavior through repeated filling of untruthful DTRs and benefiting from these illicit gains through continued salary pay outs while only sometimes attending work, the integrity of the Court would undoubtedly suffer a major blow should these unscrupulous activities go unpunished.

The Court also addressed the liability of Judge Calimag, Jr., for enabling Abdullahi’s misconduct. Although he could not be sanctioned by way of administrative liability considering he had already been dismissed from his judicial functions on February 26, 2002. This prior judgement involved issues relating to dishonesty of the honorable judge with regards to gross misconduct, willful failures to pay debt and also violating Canons of Judicial Ethics and the Code of Judicial Conduct. Considering, however, the circumstances that lead to Abdullahi’s dishonest filling of DTRs, he would be suffering the same penalty as the dismissed court interpreter.

Finally, the Court considered the liability of Clerk of Court Paul R. Attolba, Jr., who had signed Abdullahi’s falsified DTRs. Attolba argued that he had relied on Judge Calimag, Jr.’s, authorization in approving the DTRs. The Supreme Court held that Attolba could not entirely escape responsibility, as he had a duty to ensure the accuracy of official records. Condoning the act just because it came from a superior, however, would not suffice as a proper and moral explanation for not intervening or attempting to report or take issue of these questionable actions. For this, he was found liable and penalized for Two Thousand Pesos, despite recommendation to initially have him fined Five Thousand Pesos. The fact that he did not fully understand his function as the Court’s Clerk with due and ethical purpose resulted in this penalty being reduced.

Building on the court’s final ruling, it reiterated the need to consider personal liabilities and administrative judgement involving judges such as Hon. Tumaliuan. Despite initial inclination of promoting personnel from the Court deemed suitable based on certain capabilities and standards such as diligence, industrious nature and other positive qualities; however, current standards and on-goings that have occurred since his employment in Court were to be considered. These standards were in place so the promotion for certain Court members would have integrity and with pure intent.

This case shows, without a shadow of doubt, the administrative repercussions that are to be carried by the individuals proven to act and have acted dishonestly in their government posts and responsibilities. Not only are they held responsible through administrative proceedings for their untruthful and unlawful actions; in addition, they may also bear other types of charges dependent on their individual circumstances such as estafa or tax-related penalties in relation to falsifying documents and obtaining salaries for time or for activities never truthfully delivered.

FAQs

What was the key issue in this case?	The key issue was whether a court employee should be dismissed from service for falsifying her Daily Time Records (DTRs) while simultaneously attending law school.
What is a Daily Time Record (DTR)?	A DTR is an official document used by government employees to record their daily attendance and work hours. It serves as the basis for calculating their salary.
What is the penalty for falsifying a DTR?	Under Civil Service rules, falsification of an official document is a grave offense punishable by dismissal from the service.
Can a judge authorize a court employee to be absent from their official station?	While a judge may authorize occasional absences for official business, they cannot authorize prolonged absences for personal reasons. In order for personnel not be remiss of their assigned tasks, it is best that personnel and administrative actions comply fully with civil service requirements and requirements set by the Court of the Philippines.
Was Judge Calimag, Jr., held liable in this case?	He was found to be liable for facilitating employee, Abdullahi’s unlawful activity in relation to not filling out and accurately writing on official DTRs for continued remittance to her by way of earnings and continued employment despite her unlawful attendance; however, because he was dismissed at an earlier date, he can no longer be reprimanded as the judge position is no longer something he holds.
What was Clerk of Court Attolba, Jr.’s, involvement in the case?	Attolba, Jr., signed Abdullahi’s falsified DTRs. He was ultimately given a fine in the amount of two thousand pesos. He was likewise duly warned to comply and adhere to standards and procedures required of the court to avoid such events and to promote complete attendance and overall transparency when attending his duties as an officer in court.
What is the importance of honesty in public service?	Honesty and truthfulness are essential for maintaining public trust and confidence in government institutions. Court employees are expected to be accountable and truthful for accurate delivery of public service and to set exemplary examples of conduct for others to learn and mirror. Public personnel and government employees ought to mirror truth in the fulfillment of assigned official responsibilities and roles.
What factors affect the assignment or reassignment of government employees to Court locations?	Certain factors in light of personnel decisions of the Supreme Court of the Philippines require merit and urgency in the assignment of duties and for the personnel in public courts to accomplish their daily responsibilities. Public need and interest is a greater public good consideration more often than not compared to that of employee convenience and personal comfort.

This case serves as a reminder to all court employees and public servants about the importance of integrity and honesty in the performance of their duties. Falsifying official documents and receiving compensation for work not rendered are serious offenses that undermine public trust and erode the credibility of government institutions. A similar Court case in the future may require closer perusal from civil authorities and employees of administrative liability where said offenses will also involve unlawful administrative activity of continued disbursement of salary by individuals and institutions. To further reinforce legal safeguards the current system needs constant inspection so that there would likewise have more transparency, strict policies of law, regulations of court in order to guarantee the integrity of records and maintain efficiency.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: THE COURT ADMINISTRATOR, COMPLAINANT, VS. LIZA MARIE F. ABDULLAHI, COURT INTERPRETER III, RTC-BR. 15, ALFONSO-LISTA, IFUGAO, RESPONDENT., A.M. No. P-02-1560, March 20, 2002